Document gDGkajzK9qG3N9p6BvmvjwVZQ

FILE NAME: Westinghouse (WH) DATE: 1975 Oct DOC#: WH039 DOCUMENT DESCRIPTION: Excerpt from Consultant Report 'Technological Feasibility and Economic Impact of OSHA Proposed Revision to the Asbestos Standard1 czy~o^ Excerpt fro "Technologleal Feasibility and Econoaic lapact of OSHA Proposed Envision Co the Asbestos Standard" prepared bp HESTON Envlronaental Consultants. With verification still required in the secondary and conruaer segaents of the industry, it now is possible to conclude: 1. That it is not technically feasible for any segaent of the asbestoe Industry to asst a O.S fiber per cc (TVA) exposure level. 2. That the priaary producers can, at substantial cost, within three to five years aest the 2 fibers per ee (TVA) standard. 3. That large portions of the secondary and eonsuaer segaents of the Industry cannot econoalcally (and perhaps cannot techno logically) aeet the 2 fibers per ce (TVA) standard without the option of using personal protection as their priaary aode of coapllance, particularly when they aust shoulder the paes-through costs of "beat available technology" (BAT) in the priaary sector. 4. That the enforceaent, without exceptions, within the secondary and eonsuaer segaents of the industry, of the July 1, 1976, 2 fibers per cc (TVA) standard, and, a fortiori. change in the standard to any lower level, will lead to undesirable con centration within the industry. 5. That, because the projected construction industry regulation inevitably will have a profound econoaic lapact upon segaents of the asbestos aanufacturing Industry, we cannot intelligently coaaent upon the econoaic lapact of the proposed aanufacturing regulation separate and apart froa the econoaic lapact of the projected construction regulation. He believe, in short, that the aost serious probleas raised by the reguletloo proposed on October 9, 1973 lie in its potential lapact upon the secondary and eonsuaer segaents of the industry.... 03114827